Summary of Five Document Reviews 

Approved by the Subcommittee for 

Procedure Reviews

Kathleen Behling, SC&A, Inc.

Advisory Board on Radiation and Worker Health, 

Subcommittee for Procedure Reviews

August 16, 2023
2

SPR-approved documents

 OCAS-TIB-009, rev. 0, “Estimation of Ingestion 

Intakes”/NIOSH-OVER-0002, rev. 0, “Workplace Ingestion”

 ORAUT-PROC-0031, rev. 01, “DOE Technical Basis Document 

Development, Review, and Approval Process”

 ORAUT-OTIB-0083, rev. 00, “Dissolution Models for Insoluble 

Plutonium-238,” superseded by DCAS-RPT-005, rev. 01, 

“Alternative Dissolution Models for Insoluble Pu-238”

 OCAS-PER-020, rev. 0, “Blockson TBD Revision”

 OCAS-PR-007, rev. 1, “Dose Reconstruction Review”
3

Matrix-style presentation approach

 At the April 14, 2021, Board meeting, the SPR presented their 

approach for closing out SPR-approved documents

 Issue resolution matrix approach was agreed upon:

– Summary description of document reviewed

– Inclusion of a table listing:

• Description of document review findings/observations

• Chronology of NIOSH, SC&A, and SPR discussions to resolve issue

• Summary of final finding/observation resolution

 Matrix approach only for less complex documents

 OCAS-TIB-009/NIOSH-OVER-002 are not suitable for this 

matrix-style approach
4

OCAS-TIB-009, rev. 0

 Title: “Estimation of Ingestion Intakes” 

 Issued April 13, 2004

 Provides approach to estimating ingestion intakes for workers 

without bioassay monitoring data 

 Used to estimate ingestion intakes during both operational and 

residual contamination periods

 Relies on ambient air concentration measurements to estimate 

the amount of daily ingestion in the workplace
5

SC&A’s review of OCAS-TIB-009

 SC&A reviewed OCAS-TIB-009 in June 2006

 SC&A identified a set of related findings associated with 

surface contamination:

– Surface contamination levels are likely orders of magnitude higher than 

predicted by the settling velocity of airborne contaminants assumed at 

5 microns 

– NIOSH’s assumption that equilibrium is reached in a 24-hour period is 

without scientific basis and unconservative

– Surface contamination may also result from milling, grinding, cutting, 

welding, liquid spills, etc.
6

SC&A’s modeled transfer findings

 SC&A identified a set of related findings associated with 

modeled transfer:

– Modeled transfer of surface contaminations to the mouth that assumes 

a 10% transfer from the surface area of one hand during a full workday 

appears unrealistic and unconservative

– Ingestion may involve other modes of intake, such as direct deposition 

on lips, smoking of cigarettes, etc.
7

SC&A’s review of OCAS-TIB-009: Finding 1

 SC&A findings later consolidated into the BRS as TIB-009 

finding 1

 BRS TIB-009 finding 1: The fundamental scientific approach 

to reconstructing ingestion exposures has flaws that could lead 

to an underestimate of ingestion doses under certain 

circumstances

 SPR determined that this TIB-009 finding was an overarching 

issue

 NIOSH issued NIOSH-OVER-0002, rev. 00, “Workplace 

Ingestion,” October 26, 2012
8

NIOSH’s response to SC&A’s TIB-009 review

 NIOSH prepared a white paper on SC&A’s TIB-009 findings 

and presented its results at the November 1, 2012, SPR 

meeting

 NIOSH concurred that parameters used in the TIB-009 model 

are based on assumptions that have not been empirically 

demonstrated to be valid

 NIOSH characterized SC&A’s findings into two issues: 

– Issue 1: The possible lack of an association between measured air 

concentrations in the workplace and surface contamination 

– Issue 2: The modeled transfer of the surface contamination to the GI 

tract through inadvertent ingestion
9

NIOSH on issue 1: Relationship between air 

and surface contamination levels

 NIOSH analyzed air and smear sampling from:

– Simonds Saw and Bethlehem Steel uranium rolling operations

– Superior Steel during a test rolling

– Vitro Manufacturing (~240 air samples and 150 contamination smears)

 Paired data were plotted and showed measured surface 

contamination levels are proportional to air contamination

 Linear regression analysis showed estimated level of surface 

contamination (dpm/m2) equals 116.7 times measured air 

concentration (dpm/m3)
10

NIOSH on issue 2: Determine daily ingestion 

rate for loose surface contamination

 NRC computer program RESRAD-BUILD has an ingestion 

parameter based on an extensive review and analysis of the 

literature

 In this model, the hourly ingestion rate (dpm/h) equals the surface 

contamination measured in the workplace (dpm/m2) times effective 

transfer rate for ingestion of removable contamination (m2/h)

 NUREG/CR-5512, volume 3, considered the average value of 

1.1×10-4 m2/hr (corresponding to an ingestion of about 0.5 mg/day) 

to represent the default ingestion transfer rate

 Corresponding ingestion rate for an 8-hour workday would be 

8.8×10-4 m2/d
11

Relationship between air concentration, 

surface contamination, and default daily ingestion 

 Using the NIOSH-derived 

surface contamination level 

(116.7) and NUREG/CR5512 default ingestion value 

(8.8×10-4 m2/d) results in 

daily ingestion of 0.103 times 

measured air concentration 

in workplace

 TIB-009 guidance 

recommends a daily 

ingestion of 0.2 times 

measured air concentration 

in workplace
12

NIOSH conclusion on TIB-009 guidance

 Using empirical data and NUREG/CR-5512 default ingestion rate, 

ingestion intake predictions are approximately half those 

recommended in TIB-009

 Although TIB-009 parameters and assumptions were somewhat 

simplistic, the model produces estimates of ingestion in reasonable 

agreement with the NUREG predictions 

 TIB-009 also includes a 20% multiplier for a contaminated beverage 

or food item, not considered in the NUREG 

 Given the uncertainty inherent in the values, it is not unreasonable 

for NIOSH to continue using the TIB-009 approach for estimating 

intakes
13

Additional NIOSH ingestion considerations

 Using TIB-009, ingestion will be a fraction of the inhalation exposure 

(1 dpm/m3 of air activity results in daily inhalation and ingestion 

exposures of 9.6 dpm/day and 0.2 dpm/day, respectively)

 For uranium intakes, uptake across the gastrointestinal (GI) tract is 

low 

 Ingestion pathway contributes less than 0.6% to the dose for soft 

tissues under all solubility types 

 Maximum contribution for ingestion would be to organs of the GI 

tract, with highest dose of 3.4% to the lower large intestine 

assuming inhalation of Type S material

 For ingestion dose, NIOSH applies a geometric standard deviation 

(GSD) of 3; in some cases, a GSD of 5 is applied 
14

NIOSH on using TIB-009 guidance for 

residual period

 TIB-009 has been improperly applied during the residual period

 After Atomic Energy Commission operations, estimating air concentration 

using a resuspension factor (e.g., 1x10-6/m) and multiplying that value by 

0.2 to calculate a daily ingestion intake would grossly underrepresent 

airborne activity that would deposit the surface contamination

 To apply TIB-009 during residual periods, air concentration on the first day 

of the residual contamination period should be equal to that present at the 

end of operations

 Thereafter, ingestion can be decreased over time using ORAUT-OTIB0070 source depletion techniques

 NIOSH will comprehensively review estimation of ingestion during the 

residual contamination period at all sites and issue PERs as appropriate
15

SC&A’s response to NIOSH’s TIB-009 ingestion 

assessment

November 1, 2012, SPR meeting, SC&A identified:

 Majority of data on inadvertent ingestion from hand-to-mouth 

behavior are in residential setting and may not represent industrial 

environment

 Data in NUREG-5512 and RESRAD came from Pacific Northwest 

Laboratory and represent one set of data

 An independent EPA study on World Trade Center (WTC) workers 

used a model for transferring pesticides hand to mouth

– EPA study found on soft surfaces ingestion was 2.25 cm2/hr, which agrees 

with NIOSH

– EPA’s hard surface values were 11.25 cm2/hr
16

NIOSH’s response to WTC study

On January 4, 2013, NIOSH responded to WTC study:

 EPA document was developed to identify contaminants of 

primary health concern in support of planned residential 

cleanup efforts 

 Methodology oriented toward screening analysis of exposures 

to residents in vicinity of WTC and not toward quantification of 

exposure to WTC cleanup workers

 Considering this, DCAS believes that occupational ingestion 

parameters in RESRAD document remain the best set of data 

to estimate ingestion exposures under EEOICPA
17

Closure of BRS finding 1 for TIB-009 and 

OVER-0002

 SC&A concluded:

– Considering (1) the differences between the WTC study and TIB-009 

and (2) all the uncertainties involved, the amount of agreement 

between the hand-to-mouth effective transfer rates is reasonable

– Difference in hand-to-mouth ingestion model between workers and 

residents is exposure durations assumed, not the effective transfer 

rates

 SC&A therefore recommended closure

 Considering all discussions, SPR closed TIB-009 and OVER0002 finding 1 at the February 5, 2013, meeting
18

Discussion on TIB-009/OVER-002
19

ORAUT-PROC-0031

 Rev. 01, “DOE Technical Basis Document Development, 

Review, and Approval Process,” issued December 15, 2005

 Rev. 02, “Site Profile and Technical Basis Document 

Development,” issued August 17, 2007

 Establishes guidelines for the development, review, and 

approval of site profile technical basis documents (TBDs)

 Content is procedural rather than technical
20

SC&A’s review of PROC-0031

 SC&A’s review of rev. 0 submitted June 8, 2006

 SC&A review of rev. 01 submitted August 3, 2007

 Review conducted in accordance with “SC&A’s Procedure to 

Perform QA Reviews of NIOSH/ORAU Dose Reconstruction 

Procedures,” rev. 0, April 12, 2004

 Review used QA-related document compliance checklist

 SC&A identified three findings
21

Issue resolution for PROC-0031 finding 1

Finding date Finding description NIOSH response Finding resolution

6/8/2006 Section 4.2.1 appears to 

incorrectly reference other 

sections in the procedure. 

The correct reference 

should be: “Sections 

6.3.10 through 6.3.15.”

8/24/2007. NIOSH 

agrees. This error was 

corrected through a 

page change to the 

procedure.

11/2/2007. Issue 

resolved to the 

satisfaction of the 

Subcommittee and 

the finding was 

closed.
22

Issue resolution for PROC-0031 finding 2

Finding date Finding description NIOSH response Finding resolution

6/8/2006 Section 4.2.7 refers to 

“sensitive 

information” but does 

not define what is 

meant by that term. 

The definition section 

(section 9.0) likewise 

does not define that 

term.

8/24/2007. “Sensitive 

information” as used in this 

Procedures is a general, 

collective description of 

information that has limited or 

restricted access and 

distribution due to various 

laws, regulations, and agency 

orders, i.e., Privacy Act, DOE 

Order 471.1A (Unclassified 

Controlled Nuclear material), 

DOE Order 471.3 (Official Use 

Only Information), etc.

11/2/2007. Issue 

resolved to the 

satisfaction of the 

Subcommittee and 

the finding was 

closed.
23

Issue resolution for PROC-0031 finding 3

Finding date Finding description NIOSH response Finding resolution

6/8/2006 The procedure covers 

TBD revision reflecting 

comments from NIOSH 

and worker outreach 

activities but does

not mention those 

received from reviews by 

the Advisory Board or its 

contractors. Are they 

assumed to be

NIOSH comments?

8/24/2007. Yes. NIOSH 

forwards comments 

from the Advisory Board 

and its contractors to 

ORAU for response and 

followup.

11/2/2007. Issue 

resolved to the 

satisfaction of the 

Subcommittee and the 

finding was closed.
24

PROC-0031 followup

 November 1, 2012, SPR requested SC&A to perform a prereview of PROC-0031, rev. 03

 SC&A submitted its pre-review report on January 25, 2013

 SC&A concluded:

– Revision contained no material technical changes

– Revision is substantial improvement over earlier version with more 

clarity and details

 July 9, 2013, SPR concluded that a re-review of PROC-0031 

was not required and added a note to the BRS to that effect
25

Discussion on PROC-0031
26

ORAUT-OTIB-0083

 Rev. 00, “Dissolution Models for Insoluble Plutonium-238,” 

issued April 12, 2013

 OTIB reviews two specific examples of nonstandard urinary 

excretion patterns following intakes of ceramic forms of Pu-238 

and provides parameters for their use in IMBA

 Energy employees (EEs) exposed to this ceramic form of 

Pu-239 exhibit non-monotonic urinary excretion, where there is 

a length of time the urine shows nothing and thereafter it goes 

back to be excreted

 OTIB cancelled and replaced by DCAS-RPT-005 in 2016 
27

SC&A’s review of ORAUT-OTIB-0083

 Review submitted December 24, 2013

 Review identified 14 findings

 Findings discussed at February 13, 2014, SPR meeting
28

OTIB-0083 finding 1

Finding date Finding description NIOSH response Finding resolution

12/24/2013 The applicability and 

target audience of 

ORAUT-OTIB-0083 is not 

well defined

2/13/2014. This is an 

administrative finding 

that NIOSH can 

address as appropriate.

2/13/2014. SPR 

requested that NIOSH 

provide followup 

actions at a future 

SPR meeting.
29

OTIB-0083 finding 2

Finding date Finding description NIOSH response Finding resolution

12/24/2013 NIOSH did not 

demonstrate that Type J 

plutonium is a material 

that would be 

rarely encountered in 

the workplace.

2/13/2014. Type J Pu has 

only been observed at 

LANL. When Pu is 

incorporated into a 

ceramic matrix material, it 

displays a protracted 

period of increasing 

solubility over time, then 

decreases. Although this 

material was present at 

Mound, no instances of 

inhalation.

2/13/2014. SPR 

requested that NIOSH 

provide followup 

actions at a future 

SPR meeting.
30

OTIB-0083 finding 3

Finding date Finding description NIOSH response Finding resolution

12/24/2013 NIOSH does not explain 

why Type L was chosen to 

evaluate the doses for 

certain scenarios, as 

exemplified in tables 2-1 

and 2-2. Type L was 

derived based on a 

singular incident that 

occurred at Mound in 

1960.

2/13/2014. Type L 

model was based on 5 

cases with individual 

bio-variability. SC&A’s 

example case that does 

not fit Type L may have 

involved an EE with a 

chronic exposure. 

NIOSH will prepare a 

future written response.

2/13/2014. SPR 

requested that NIOSH 

provide followup 

actions at a future 

SPR meeting.
31

OTIB-0083 finding 4

Finding date Finding description NIOSH response Finding resolution

12/24/2013 NIOSH did not 

demonstrate that Type L 

was commonly found in 

the workplace at Mound or 

at any other places.

2/13/2014. SC&A 

responded by stating its 

concern in this finding is 

whether the OTIB will be 

used at other sites.

2/13/2014. NIOSH 

considered this finding 

similar to finding 3. TIB 

actually instructs dose 

reconstructors to use 

Type L under certain 

circumstances. NIOSH 

does not understand 

issue.

2/13/2014. SPR 

requested that NIOSH 

provide followup 

actions at a future 

SPR meeting.
32

OTIB-0083 finding 5

Finding date Finding description NIOSH response Finding resolution

12/24/2013 NIOSH did not 

demonstrate that 

exposures at Mound to 

Pu-238 that show nonmonotonic absorption 

from the lungs may be 

well-characterized by 

Type L Pu-238 at all times 

and at all areas.

2/13/2014. NIOSH will 

provide a future 

response to finding.

2/13/2014. SPR 

requested that NIOSH 

provide followup 

actions at a future 

SPR meeting.
33

OTIB-0083 finding 6

Finding date Finding description NIOSH response Finding resolution

12/24/2013 NIOSH does not state 

whether the technical 

calculations to derive the 

limiting dissolution types 

should stand as examples 

of similar calculations to 

be performed for other 

facilities besides Mound.

2/13/2014. NIOSH 

stated that it is implied 

that OTIB-0083 will be 

used at other facilities 

but agrees OTIB does 

not adequately describe 

the basis for its use at 

other facilities.

2/13/2014. SPR 

requested that NIOSH 

provide followup 

actions at a future 

SPR meeting.
34

OTIB-0083 finding 7

Finding date Finding description NIOSH response Finding resolution

12/24/2013 NIOSH does not compare 

organ doses from acute 

intakes of Type L Pu-238 

with chronic intakes of 

Types M and S Pu-238 

materials. NIOSH should 

discuss the limiting 

dissolution types for acute 

intakes of Type L versus 

chronic intakes of Type M 

or Type S Pu-238, as this 

is an important problem in 

dose reconstruction.

2/13/2014. NIOSH does 

not understand basis for 

finding but will address 

the finding in the 

context of SC&A’s 

report.

2/13/2014. SPR 

requested that NIOSH 

provide followup 

actions at a future 

SPR meeting.
35

OTIB-0083 finding 8

Finding date Finding description NIOSH response Finding resolution

12/24/2013 In section 4, NIOSH 

defines the parameters for 

Type L exposures at 

Mound and compares the 

dissolution curves with 

Type J and Type S, but 

does not demonstrate that 

Type L is typical of Mound 

exposures.

2/13/2014. NIOSH will 

discuss and 

demonstrate that the 

Type L solubility is 

adequately bounding. 

NIOSH will provide 

written response.

2/13/2014. SPR 

requested that NIOSH 

provide followup 

actions at a future 

SPR meeting.
36

OTIB-0083 finding 9

Finding date Finding description NIOSH response Finding resolution

12/24/2013 The purpose of section 4 

is not well defined in 

relation to other 

exposures to Pu-238 that 

show non-monotonic 

behavior at Mound and at 

other sites.

2/13/2014. NIOSH will 

provide written 

response to finding.

2/13/2014. SPR 

requested that NIOSH 

provide followup 

actions at a future 

SPR meeting.
37

OTIB-0083 finding 10

Finding date Finding description NIOSH response Finding resolution

12/24/2013 There is no guidance in 

either ORAUT-TKBS0016-5, rev. 02, or OTIB0083 on which areas of 

Mound and in which time 

period tables 2-1 and 2-2 

should be used. The lack 

of such guidance implies 

that the tables should be 

used at all areas and at all 

times to interpret Mound 

Pu-238 bioassay results.

2/13/2014. NIOSH 

stated that it is their 

intent to use the table 

values for all areas and 

all times for all 

plutonium intakes.

2/13/2014. SPR 

requested that NIOSH 

provide followup 

actions at a future 

SPR meeting.
38

OTIB-0083 finding 11

Finding date Finding description NIOSH response Finding resolution

12/24/2013 There is no assurance that 

the Pu-238 material at other 

sites will correspond to 

Mound’s Type L PU-238 lung 

dissolution pattern. There is 

no information in OTIB-0083 

on how to deal with 

exposures to Pu-238 

material that present lung 

dissolution parameters 

different from Types M, S, 

and L.

2/13/2014. NIOSH 

will address finding in 

future written 

response.

2/13/2014. SPR 

requested that 

NIOSH provide 

followup actions at a 

future SPR meeting.
39

OTIB-0083 finding 12

Finding date Finding description NIOSH response Finding resolution

12/24/2013 OTIB-0083 is difficult to 

follow and understand. The 

sections do not follow a 

natural order. NIOSH’s 

Type J and Type L Pu-238 

compounds are only 

introduced in section 4, 

although they are used in 

sections 1, 2, and 3.

2/13/2014. NIOSH 

will take this finding 

under consideration 

as they are providing 

these responses.

2/13/2014. SPR 

requested that 

NIOSH provide 

followup actions at a 

future SPR meeting.
40

OTIB-0083 finding 13

Finding date Finding description NIOSH response Finding resolution

12/24/2013 OTIB-0083 is essentially the 

same document as the 

white paper, “Modeling 

Intakes of Pu-238 at Mound.” 

OTIB-0083 is only clear for 

those that participated in 

discussions about Pu-238 

exposures at Mound.

2/13/2014. It was 

discussed that this is 

an editorial comment 

about clarity of the 

document. It will be 

taken into 

consideration in the 

response. Also, this 

may be an 

observation rather 

than finding.

2/13/2014. SPR 

requested that 

NIOSH provide 

followup actions at a 

future SPR meeting. 

The SPR also 

determined that the 

issue will remain a 

finding awaiting 

NIOSH’s response.
41

OTIB-0083 finding 14

Finding date Finding description NIOSH response Finding resolution

12/24/2013 OTIB-0083 does not discuss 

the existence of other 

non-monotonic forms of Pu238 at Mound, nor present 

any research done to prove 

Type L is the only 

appropriate form of Pu-238 

to be included in the 

calculation of the limiting 

dissolution type.

2/13/2014. NIOSH 

considers this proving 

a negative issue. 

OTIB does 

demonstrate why this 

is not considered to 

be a reasonable 

incident at Mound. 

NIOSH will reiterate 

issue in response.

2/13/2014. SPR 

requested that 

NIOSH provide 

followup actions at a 

future SPR meeting.
42

NIOSH followup response about OTIB-0083 

at August 28, 2014, SPR meeting

 NIOSH agrees with SC&A’s 

comment that target 

audience not well defined.

 NIOSH agrees with concerns 

about applicability of the 

Type L model developed 

using 5 Mound cases.

 NIOSH will rebuild model 

based on additional cases at 

Mound.

 NIOSH will demonstrate that 

the Type L exposures are 

standard anywhere Pu-238 is 

handled.

 NIOSH will add section that 

defines scope and 

specifically under which 

exposure conditions we can 

expect Type L material to be 

present.
43

SPR discussions about OTIB-0083 at the 

November 25, 2014, meeting

 NIOSH will evaluate at which sites this Pu-238 may have 

existed.

 Planning on doing a complete rewrite of OTIB-0083.

 On NIOSH’s project planning chart for review in the May 2015 

timeframe, with completion in August 2015.

 NIOSH will inform SPR when rewrite complete.

 Thereafter, SC&A will be tasked with review.
44

DCAS-RPT-005

 Rev. 00, “Alternative Dissolution Models for Insoluble Pu-239,” 

issued June 30, 2016, replaced ORAUT-OTIB-0083

 Rev. 01 issued August 17, 2018

 Provides guidance on the evaluation of intakes for workers who 

were exposed to insoluble ceramic forms of Pu-238

 LANL, Mound, SRS, and NUMEC only sites with 

unencapsulated insoluble Pu-238

 Site-specific dissolution models developed for Mound and 

LANL
45

SC&A’s review of RPT-005, rev. 00

 Review submitted January 13, 2017.

 Assessment of RPT-005 resulted in SC&A recommending that all 14 

findings on OTIB-0083 be closed:

– RPT-005 clearly defines the target audiences and DOE and AWE sites that 

had the potential for exposure to this form of plutonium.

– RPT-005 refers to the application of lung model “Type L” at Mound and other 

sites; NIOSH now differentiates the sites (LANL, SRS, NUMEC, and Mound). 

For Mound in particular, data from various incidents are used to derive the 

most suitable model for Pu-238 to be applied in the installation.

– RPT-005 now specifies how alternative dissolution models for Pu-238 should 

be applied to different installations.

– Findings 7, 8, 12, and 13 no longer apply to RPT-005.

 Review did identify two new findings.
46

RPT-005 finding 1

Finding date Finding description NIOSH response Finding resolution

01/13/2017 NIOSH should provide 

justification for using 

Mound Case 13 dissolution 

parameters as the default 

for all Mound workers.

2/26/2019. SC&A 

submitted a memo 

indicating it reviewed 

DCAS-RPT-005, rev. 01, 

and considers their 

justification for using 

Case 13 adequate. 

Recommends closure.

11/13/2017. NIOSH will 

add explanation in next 

revision.

10/17/2018. NIOSH 

issued RPT-005, rev. 01, 

which added clarification 

as to why Case 13 

represents all Mound 

workers.

11/13/2017. Due to 

the nature of this 

concern, the finding 

was changed to an 

observation. SPR 

put it in abeyance 

awaiting RPT 

revision.

2/18/2021. SPR 

closed observation.
47

RPT-005 finding 2

Finding date Finding description NIOSH response Finding resolution

01/13/2017 The use of Mound 

Case 13 parameters as 

a default for SRS 

workers contradicts the 

more claimantfavorable statement 

that the LANL model 

should be used for SRS 

cases.

11/13/2017. NIOSH 

agrees that the 

statement is in error and 

will be corrected 

through the issuance of 

a page change notice.

10/17/2018. NIOSH 

issued RPT-005, 

rev. 01, which corrects 

the error.

11/13/2017. Due to the 

nature of this concern, 

the finding was changed 

to an observation. SPR 

put it in abeyance 

awaiting RPT revision.

2/13/2019. NIOSH has 

revised report and 

corrected error on using 

Mound-13 for SRS. SPR 

closed observation.
48

Discussion on RPT-005
49

OCAS-PER-020, rev. 0

 Title: “Blockson TBD Revision”

 Issued July 31, 2007

 Determines the effect of revision 01 to the Blockson Chemical 

Company TBD (OCAS-TKBS-0002)

 Revision impacted several exposure pathways:

– Inclusion of non-uranium activities in dose reconstruction

– Revised intakes for uranium extraction in building 55

– Revision to radon exposure estimates

– Revisions to doses from residual contamination
50

SC&A’s review of PER-020, rev. 0

 Review issued March 23, 2009

 Identified three findings

 SC&A presented review to the SPR at the March 22, 2011, 

meeting
51

PER-020 finding 1

Finding date Finding description NIOSH response Finding resolution

3/23/2009 NIOSH’s assigned 

solubility class Type M 

for uranium and its 

use for converting 

urine excretion data to 

inhalation quantities 

for building 55 may be 

inappropriate.

3/22/2011. Finding 

discussed and 

determined to be 

complex and specific to 

the Blockson site profile 

rather than the PER.

7/31/2012. NIOSH 

reports that there is no 

reason to believe that 

there is anything other 

than Type M solubility at 

Blockson. SC&A agrees.

3/22/2011. SPR decided 

that the Blockson Work 

Group should be 

reconstituted for the 

purpose of resolving this 

finding. SPR requested 

that NIOSH investigate 

the impacts of this issue 

and report back to the

Subcommittee.

7/31/2012. SPR closed 

finding.
52

PER-020 finding 2

Finding date Finding description NIOSH response Finding resolution

3/23/2009 NIOSH’s assigned f1

value of 0.02 for 

uranium and its use 

for converting urine 

excretion data to 

inhalation/ingestion 

quantities may be 

inappropriate.

3/22/2011. Finding 

discussed and 

determined to be 

complex and specific to 

the Blockson site profile 

rather than the PER.

7/31/2012. NIOSH 

reports that there is no 

reason to believe that 

there is anything other 

than Type M solubility at 

Blockson. SC&A agrees.

3/22/2011. SPR decided 

that the Blockson Work 

Group should be 

reconstituted for the 

purpose of resolving this 

finding. SPR requested 

that NIOSH investigate 

the impacts of this issue 

and report back to the

Subcommittee.

7/31/2012. SPR closed 

finding.
53

PER-020 finding 3

Finding date Finding description NIOSH response Finding resolution

3/23/2009 The assigned radon 

exposure value of 0.112 

wlm/year as a bounding 

value for Blockson may be 

inappropriate.

3/22/2011. An SEC 

has been awarded at 

Blockson, which 

states radon 

exposures cannot be 

modeled. Therefore, 

this finding is moot.

3/22/2011. Based on 

the issuance of the 

Blockson SEC, the 

SPR closed the 

finding.
54

SC&A’s subtask 4 review of PER-020, rev. 0

 Two cases were selected for review

 Both cases were reworked after TBD revision 02 was issued in 

November 2007

 Subtask 4 report issued October 15, 2013

 SC&A identified three findings

 Review presented to SPR at November 13, 2013, meeting
55

Subtask 4 case overview

 EEs for both cases worked at Blockson for many years

 Neither of the EEs were monitored for exposure

 Both EEs were diagnosed with a qualifying cancer during 

employment

 SC&A compared original and reworked dose

 As expected, external and internal doses increased in both 

cases

 SC&A’s assessment to determine if reworked cases were 

performed in accordance with TBD revision resulted in three 

findings
56

PER-020 finding 4 (subtask 4)

Finding date Finding description NIOSH response Finding resolution

10/13/2013 Internal dose calculation 

inconsistent with guidance 

in OCAS-TKBS-0002, 

rev. 02. Internal doses 

calculated for stomach 

based on inhalation 

pathway. Guidance 

specifies doses should be 

calculated using the 

ingestion pathway for 

cancers associated with 

organs/tissues of the GI 

tract.

11/7/2013. NIOSH agrees. 

NIOSH re-reviewed all the 

cases that had GI tract 

cancers and found

there were six cases that 

had been done incorrectly, 

since they did not use 

ingestion. Four were 

compensated under SEC. 

Two were reworked but no 

change in compensation 

decision.

11/7/2013. Based 

on NIOSH’s 

reassessment of all 

impacted cases, the 

SPR closed finding.
57

PER-020 finding 5 (subtask 4)

Finding date Finding description NIOSH response Finding resolution

10/13/2013 Calculation of inhalation 

dose was not consistent with 

OCAS-TKBS-0002, rev. 02, 

guidance. Inhalation dose 

only considered intakes from 

Th-232, U-234, and U-238, 

rather than all 12 

radionuclides identified in 

TBD.

4/16/2014. SC&A reviewed 

the tool and finds it 

acceptable.

11/7/2013. NIOSH 

agrees. NIOSH 

reviewed the case 

and determined that 

the inhalation dose 

had been completed 

with an old version of 

the Building 55 

Inhalation Tool. Tool 

has been revised.

11/7/2013. SPR 

tasked SC&A with 

reviewing the revised 

tool.

4/16/2014. Based on 

SC&A’s review, SPR 

closed the finding.
58

PER-020 finding 6 (subtask 4) 

Finding date Finding description NIOSH response Finding resolution

10/13/2013 Identification of a potential 

error in the Blockson Bldg. 55 

Inhalation Tool. 

4/16/2014. SC&A reviewed the 

tool and finds it acceptable but 

identified discrepancy between 

tool instructions and TBD.

11/25/2014. SC&A reviewed 

the modified TBD and agrees 

that the changes address the 

finding.

11/7/2013. NIOSH 

reviewed the case 

and determined that 

the inhalation dose 

had been completed 

with an old version of 

the tool. Tool has 

been revised

4/16/2014. NIOSH 

agreed to modify the 

TBD to agree with 

the latest version of 

the tool.

4/16/2014. Based 

on SC&A’s review, 

SPR changed 

finding status to in 

abeyance awaiting 

TBD change.

11/25/2014. Based 

on SC&A’s TBD 

review, SPR closed 

the finding.
59

Discussion of PER-020
60

OCAS-PR-007, rev. 1

 Title: “Dose Reconstruction Review”

 Issued April 14, 2005

 Provides guidance to OCAS personnel involved in assessing 

performance of contractor, contractor personnel, and selfassessments related to dose reconstruction under 

42 CFR Part 82

 NIOSH quality assurance and quality control procedure
61

SC&A’s review of OCAS-PR-007, rev. 1

 SC&A first submitted its review of rev. 1 on June 8, 2006

 SC&A resubmitted its review of rev. 1 on August 3, 2007, with 

no additional findings

 Review conducted in accordance with “SC&A’s Procedure to 

Perform QA Reviews of NIOSH/ORAU Dose Reconstruction 

Procedures,” rev. 0, April 12, 2004

 Review used QA-related document compliance checklist

 SC&A identified nine findings
62

PR-007 finding 1

Finding date Finding description NIOSH response Finding resolution

6/8/2006 The procedure needs to 

clarify the authority that 

establishes the frequency for 

performing the three different 

types of reviews.

8/29/2008. SC&A reviewed 

PR-007, rev. 2, and 

confirmed the procedure was 

modified as stated by 

NIOSH. Recommended 

closure.

11/7/2007. This 

document was 

revised on 2/16/2007. 

There are now two 

levels of review. 

NOCTS is 

programmed such 

that 5% of the DRs 

reviewed are 

randomly selected to 

undergo detailed 

review. 

8/21/2008. SPR 

asked SC&A to 

review the revision 

and, if there were no 

additional issues, the 

finding could be 

closed. Based on 

SC&A’s review, the 

SPR closed the 

finding and the BRS 

was updated 

10/14/2008, as 

specified by SPR.
63

PR-007 finding 2

Finding date Finding description NIOSH response Finding resolution

6/8/2006 The role of the Contract 

Oversight Team Leader 

should be delineated in 

section 4.0.

8/29/2008. SC&A reviewed 

PR-007, rev. 2, and 

confirmed the procedure was 

modified as stated by 

NIOSH. Recommended 

closure.

11/7/2007. This 

document was 

revised on 2/16/2007. 

The Contract 

Oversight Team 

leader has no specific 

responsibilities in this 

procedure.

8/21/2008. SPR 

asked SC&A to 

review the revision 

and, if there were no 

additional issues, the 

finding could be 

closed. Based on 

SC&A’s review, the 

SPR closed the 

finding, and the BRS 

was updated 

10/14/2008, as 

specified by SPR.
64

PR-007 finding 3

Finding date Finding description NIOSH response Finding resolution

6/8/2006 The procedure is not clear 

on how the cases are 

chosen for review.

8/29/2008. SC&A reviewed 

PR-007, rev. 2, and found 

that the revised document 

makes it clear how the cases 

are chosen for review. As 

such, SC&A recommends 

that this issue be closed.

11/7/2007. This 

document was 

revised on 2/16/2007. 

Every DR is reviewed 

according to the 

requirements of 

section 5.1.1, Basic 

Review and Approval. 

5% of all DRs 

reviewed are selected 

at random, 

automatically by 

NOCTS.

8/21/2008. SPR 

asked SC&A to 

review the revision 

and, if there were no 

additional issues, the 

finding could be 

closed. Based on 

SC&A’s review, the 

SPR closed the 

finding and the BRS 

was updated 

10/14/2008, as 

specified by SPR.
65

PR-007 finding 4

Finding date Finding description NIOSH response Finding resolution

6/8/2006 The procedure mentions 

training for Health Physics 

personnel reviewers but 

does not reference the 

procedure covering the 

“training process.”

8/29/2008. SC&A reviewed 

PR-007, rev. 2, and 

confirmed the procedure was 

modified as stated by 

NIOSH. Recommended 

closure.

11/7/2007. This 

document was 

revised on 2/16/2007. 

There are no training 

requirements in this 

document.

8/21/2008. SPR 

asked SC&A to 

review the revision 

and, if there were no 

additional issues, the 

finding could be 

closed. Based on 

SC&A’s review, the 

SPR closed the 

finding and the BRS 

was updated 

10/14/2008, as 

specified by SPR.
66

PR-007 finding 5

Finding date Finding description NIOSH response Finding resolution

6/8/2006 The procedure does not 

reference OCAS -PR005 for basic reviews 

(section 5.1.1) or for detailed 

reviews (section 5.1.2).

8/29/2008. SC&A reviewed 

PR-007, rev. 2, and 

confirmed the procedure was 

modified as stated by 

NIOSH. Recommended 

closure.

11/7/2007. This 

document was 

revised on 2/16/2007. 

This is a stand-alone 

document. OCASPR-005 is referenced 

in section 3.0 

references.

8/21/2008. SPR 

asked SC&A to 

review the revision 

and, if there were no 

additional issues, the 

finding could be 

closed. Based on 

SC&A’s review, the 

SPR closed the 

finding and the BRS 

was updated 

10/14/2008, as 

specified by SPR.
67

PR-007 finding 6

Finding date Finding description NIOSH response Finding resolution

6/8/2006 The procedure should 

provide guidance on what is 

meant by a “significant 

overestimate.”

8/29/2008. SC&A reviewed 

PR-007, rev. 2, and 

confirmed the procedure was 

modified as stated by 

NIOSH. Recommended 

closure.

11/7/2007. This 

document was 

revised on 2/16/2007. 

The term “significant 

overestimate” does 

not appear in the 

current revision.

8/21/2008. SPR 

asked SC&A to 

review the revision 

and, if there were no 

additional issues, the 

finding could be 

closed. Based on 

SC&A’s review, the 

SPR closed the 

finding and the BRS 

was updated 

10/14/2008, as 

specified by SPR.
68

PR-007 finding 7

Finding date Finding description NIOSH response Finding resolution

6/8/2006 The procedure should not be 

limited to “radiological 

workers.”

8/29/2008. SC&A reviewed 

PR-007, rev. 2, and 

confirmed the procedure was 

modified as stated by 

NIOSH. Recommended 

closure.

11/7/2007. The 

procedure is not 

limited to radiological 

workers. The term 

“radiological worker” 

appears in the

section that describes 

the likelihood of 

exposure.

8/21/2008. SPR 

asked SC&A to 

review the revision 

and, if there were no 

additional issues, the 

finding could be 

closed. Based on 

SC&A’s review, the 

SPR closed the 

finding and the BRS 

was updated 

10/14/2008, as 

specified by SPR.
69

PR-007 finding 8

Finding date Finding description NIOSH response Finding resolution

6/8/2006 It is suggested that the 

Record of Issue/Revisions 

provide more detailed 

information, and that revised 

sections are denoted.

8/28/2008. NIOSH maintains 

historical records of 

procedures; it is not practical 

to note in the procedure’s 

Record of Issue/Revision 

table details of revisions. 

SC&A recommends that this 

issue be closed.

11/7/2007. This is a 

good suggestion. 

Historical versions of 

procedures are 

maintained.

8/21/2008. SPR 

asked SC&A to 

review the revision 

and, if there were no 

additional issues, the 

finding could be 

closed. Based on 

SC&A’s review, the 

SPR closed the 

finding and the BRS 

was updated 

10/14/2008, as 

specified by SPR.
70

PR-007 finding 9

Finding date Finding description NIOSH response Finding resolution

6/8/2006 It would be helpful to the 

reader to include an acronym 

section in the procedure.

8/28/2008. SC&A reviewed 

PR-007, rev. 2, and found that 

NIOSH did not include an 

acronym section, although the 

NIOSH response thought it is a 

good suggestion to do so. This

is not an important issue. 

SC&A recommends that this 

issue be closed.

11/7/2007. This is 

a good suggestion.

11/21/2008. SPR 

asked SC&A to review 

the revision and, if 

there were no 

additional issues, the 

finding could be 

closed. Based on 

SC&A’s review and 

recommendation, the 

SPR closed the finding 

and the BRS was 

updated 10/14/2008, 

as specified by SPR.
71

Discussion of PR-007